Document availability, the tax-return summary and submission upon a DJP request are separate obligations. Understand the deadlines and plan your documentation work.
Required master files and local files must be available no later than four months after the end of the tax year. If Indonesia’s Directorate General of Taxes, or DJP, requests those documents for compliance supervision or a tax audit, they must be submitted no later than one month after the request is delivered. That month is not additional preparation time for documents that should already be available. PMK 172/2023, Article 18(1) and Article 34(2).
For a tax team, the task is to ensure that the documents are complete, source figures can be found and material decisions have been reviewed before the deadline. A signed adviser engagement or a draft with empty sections does not address all of those needs.
Distinguish three obligations that are often confused
| Event | What needs to be prepared | Main requirement |
|---|---|---|
| Availability of the master file and local file | Complete documents, accompanied by an availability statement signed by the party providing them | No later than four months after the tax year ends; Article 18 |
| Filing the annual corporate income tax return | Master file and local file summary attached to the return for the relevant tax year | Article 19(1)–(2) |
| DJP request for compliance supervision or a tax audit | The requested master file and local file | No later than one month after the request is delivered; Article 34(2) |
Source: PMK 172/2023, Articles 18, 19 and 34.
The availability statement accompanying the documents and the summary attached to the tax return serve different purposes. Keep both, together with relevant submission receipts. For requests outside compliance supervision and tax audits, Article 34(3) refers to the deadlines under the applicable tax provisions. Do not apply one month to every letter without checking the basis of the request.
CbCR is different again: its availability deadline is no later than 12 months after the tax year ends. Notification and submission follow separate provisions in Article 23. Do not use the CbCR deadline to determine when the master file and local file must be ready. PMK 172/2023, Article 18(2) and Article 23.
Example dates for a calendar-year company
For Tax Year 2026 ending on 31 December 2026, the four-month rule produces a deadline of 30 April 2027. For Tax Year 2025 ending on 31 December 2025, it produces 30 April 2026, which has already passed as of this article’s review date, 12 September 2026.
These dates illustrate the general rule in Article 18. Use the company’s own tax year-end and check any special provision that actually applies to that taxpayer. Do not assume that an extension or relaxation of the tax-return deadline automatically changes the TP documentation availability deadline. Article 18 establishes a separate availability obligation. PMK 172/2023, Articles 18–19.
Collect evidence as transactions occur
PMK 172/2023 requires master files and local files to be prepared using data and information available when the related-party transactions occur. Application of the arm’s length principle also rests on the actual circumstances and the time of price determination or the transaction. PMK 172/2023, Article 4(1) and Article 17(1).
In practice, retain contracts, pricing approvals, market information used and evidence of performance as they become available. At year-end, reconcile the transaction results and explain changes. Do not backdate documents to suggest that an analysis was prepared earlier.
Assign data owners and define the required output
The following is a practical checklist, not a mandatory regulatory form. The reviewing firm should adapt it to the transactions and the document contents required by Articles 29–30.
| Data or task | Suggested owner | Required output |
|---|---|---|
| Entity and related-party transaction register | Tax and finance | Scope by entity, transaction category and tax year |
| Financial statements, trial balance and general ledger | Finance | Reconciled transaction figures and tested profit |
| Contracts and amendments | Legal and transaction owner | Applicable versions, effective dates and explanations of changes |
| Functions, assets and risks | Operations and management | Who performs the work, controls decisions and bears risks |
| Evidence for services or specific transactions | Activity owner | Evidence of performance and support for preliminary analysis |
| Group master file information | Group tax or headquarters | Group information for the appropriate period |
| Method, comparables and conclusion | TP reviewer | Selection rationale, analysis and resolution of material questions |
| Availability statement, summary and archive | Tax and document provider | A consistent final package that can be retrieved |
Work backwards from the availability deadline
The following is a hypothetical internal schedule for Tax Year 2026 ending on 31 December. It is not a Librantic delivery commitment.
During 2026: map transactions, retain pricing and performance evidence, and record business changes. Do not wait until year-end to ask whether a service was provided or who bears inventory risk.
January 2027: reconcile the transaction register to the general ledger, request missing group information and assign an owner to every open question.
February 2027: complete interviews on functions, assets and risks, review specific transactions, and confirm the comparable-search strategy and method-selection rationale.
March 2027: reconcile financial information, review the draft and resolve material inconsistencies between contracts, figures and actual circumstances.
April 2027: complete the final review, prepare the availability statement and summary, and archive the final version before the availability deadline. Set an internal target ahead of the last day to leave room for corrections.
If final accounts or group information are delayed, escalate before the deadline. Identify provisional figures and document versions clearly. Do not describe a package as complete while material sections remain unfinished.
If a DJP request has already arrived
Record the delivery date, tax year, documents requested and legal basis. Ask the reviewer to confirm the deadline and submission channel, then reconcile the proposed submission with the final version and availability statement.
If documents are unavailable or late, explain the actual position to the tax adviser. Separate completing the documentation from assessing the consequences of delay. Do not assume that later completion removes a previous failure to meet a deadline. PMK 172 refers to applicable tax provisions for sanctions, so the consequences need to be assessed against the particular failure and procedure. PMK 172/2023, Articles 28 and 34–36.
Use software to support source tracing
Software can help organise sources, track versions and prepare reconciliations. The reviewer must still decide whether the information is sufficient, the analysis reflects actual circumstances and the conclusion is supported. Librantic works through tax firms that review and sign the report. How Librantic works.
Preparing TP documentation or working towards a deadline? Request a consultation and include the tax year-end, number of entities, data readiness and whether DJP has issued a request.
Sources:
PMK 172 Tahun 2023, 29 December 2023. Text also checked against the DJP-hosted English version. The Indonesian legal text governs.
Sources reviewed on 12 September 2026. Librantic workflow information refers to the public pages linked in the article.
Article 19(1)–(2) requires a summary as an attachment to the annual corporate income tax return. Having the complete documents available and submitting them when requested are separate obligations. Check the format and filing procedures applicable in the submission year. PMK 172/2023.
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